Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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HC held that reassessment proceedings for AY 2002-03 and 2003-04 were invalid as they were initiated beyond the four-year limitation period. The revenue failed to establish that the assessee intentionally suppressed material information. The error in the commencement date was considered inadvertent, not deliberate. For AY 2004-05, the reassessment was within the four-year period, but no material justification was found to reopen the original assessment. The court emphasized that reassessment is not a review process and must be based on tangible evidence of non-disclosure. Consequently, the writ appeal was dismissed, protecting the assessee's original tax assessments.
HC held that reassessment proceedings for AY 2002-03 and 2003-04 were invalid as they were initiated beyond the four-year limitation period. The revenue failed to establish that the assessee intentionally suppressed material information. The error in the commencement date was considered inadvertent, not deliberate. For AY 2004-05, the reassessment was within the four-year period, but no material justification was found to reopen the original assessment. The court emphasized that reassessment is not a review process and must be based on tangible evidence of non-disclosure. Consequently, the writ appeal was dismissed, protecting the assessee's original tax assessments.
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